Gladstones LBC help please!!

Do I have to give exhibits when referring to similar cases? Or just quote them?

Ok, here's my first draft, how does it look? I need to add some more info about how I have been fully compliant with all correspondence etc..

IN THE COUNTY COURT - Claim No.: XXXXX

Between

XXXXX(Claimant)

-and-

XXXXXX (Defendant)
____________________________
WITNESS STATEMENT
__________________________

I, XXXX of XXXXXX, am the defendant in this case.

1. The facts in this statement come from my personal knowledge. Where they are not within my own knowledge there are true to the best of my information and belief.

2. I am not liable to the Claimant for the sum claimed, or any amount at all and this is my Witness Statement in support of my defence as already filed.

3. I assert that I am the registered keeper and the driver of the vehicle in question in this case.

4. I confirm that on the date mentioned, I was attending a parents’ meeting for the Ospreys under 16s elite squad in the Llandarcy Academy of Sport, of which my son is a member of. Upon approaching the academy, stewards were stopping vehicles from entering the car park, so I was required to find alternative parking.
5. As I was also travelling with my 11 month old disabled son, who was reliant on Oxygen at the time, I had to seek parking that was in close proximity to the Academy.
6. The road leading to the land at Heritage Gate, Neath appeared to be a public road, without curb-side markings, thus I had no reason to believe that there was any restricted parking at the kerbside.
7. I noted when exiting the car and walking to the meeting, that a number of other parents’ cars were parked and present in the same location, with more arriving as I left the area.
8. Upon returning to my vehicle, approximately an hour later, I found that a Parking Charge Notice from XX (also known as XXXXXX) had been affixed to my windscreen, advising me of my “contravention” for being “Parked without clearly displaying a valid pay & display ticket or permit”
9. I noted at least 20 other cars also had ticked affixed to their windscreens. I did not, however, notice any wardens present who had or were issuing tickets.
10. After noticing the note on my windscreen, I looked around the site for appropriate signage that refers to the parking restrictions. I can confirm that signs were present, but were sparse in number and insufficient in size for ease of visibility. I refer here to paragraph 108 from The Beavis Case judgement, proving the claimant understands the importance of clear and prominent signage. The sign referred to in the Beavis case is enclosed as Exhibit IL5. When compared to the excel car park sign – Exhibit IL8, I submit that no reasonable person would agree that their terms are brief, clear and prominently proclaimed
11. After approaching the signage and studying the text, I noticed a number of confusing statements. Firstly, the sign stated that “Permit Holders Only” were permitted to park. This is prohibitive and suggests that Non-Permit Holders therefore cannot be offered a contract. This is referred to in the decision recorded by DJ Iyer in the case of Pace v Lengyel dated Exhibit.
12. Furthermore, the “Terms and Conditions” of the signage state that “Vehicles must park within a marked bay”. At the time of the incident, no bays were marked on the site, making compliance with this term impossible, even with a valid permit.
13. On 6th July 2017, I completed an appeal to XXX, as advised in the Parking Charge Notice, outlining the lack of clarity and size signage. Exhibit This appeal was subsequently rejected by XXX on 21st July 2017 and a letter was received by myself advising me of the fact. Exhibit
14. Subsequently, I received debt recovery letters from “Debt Recovery Plus” on 12th September 2017, 27th September 2017 and 12th October 2017 Exhibits requesting immediate payment of the charge. The charge had been increased from £100 to £160 in these correspondences.
15. I then received more letters on 30th October and 13th November 2017, this time from “Zenith collections Exhibits . I would like to draw the court’s attention to the wording toward the bottom of the letters which state “A court judgement or decree against you could seriously affect your ability to obtain credit in the future” I find this sentence both threatening and misleading, as to my knowledge neither a court judgement nor decree is applicable in this process, regardless of the outcome.
16. I have very serious concerns about how XXX have handled my personal information by allowing these two companies, who I know nothing about and have no connection with, to, not only know my personal details, but to have enough information about my case to be able to send such letters.

17. On 5th January 2018, I received a ’Letter before Claim’ from Gladstones Solicitors, on behalf of MPS. I replied by letter on 19th January Exhibit , requesting further copies of evidence in line with the protocol which came into force on 1st October 2017, in order to assist me with the claim in further detail. In particular, I was keen to understand details of landowner agreements in place with MPS, which would establish them as “the creditor”.
18. However, a response from Gladstones dated 19th February 2018 Exhibit advises that believed that their LBC is compliant with the up to date version of the Practice Direction for Pre-Action Protocol, and no further information was offered.
19. Again, on 25th April 2018, after receiving the claim form from the Court, I sent a letter Exhibit to Gladstones confirming my intention to contest all of the claim, and as a request under CPR 31.14 for the disclosure of documents mentioned in the claim. In particular, copies of the contract between XXXX and the landowner and proof of planning permission granted to XXXX for the erection of signage, under the Town and Country Planning Act 2007. To date, no information or acknowledgement of my request has been received.